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Welcome to our November Compliance Update.

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This month we bring you key developments across the Victorian Energy Upgrades (VEUVictorian Energy Upgrades is a Victorian government energy efficiency program that gives every Victorian household and business the opportunity to receive rebates or discounts on energy saving products.), NSW Energy SavingsElectricity or gas savings or both. Scheme (ESSThe NSW Energy Savings Scheme (ESS) provides financial incentives to install, improve or replace energy savings equipment and appliances in NSW households and businesses. The ESS was established in 2009. Financial incentives are in the form of tradeable certificates, called energy savings certificates (ESCs). Generally, householders and businesses who fund energy savings activities transfer the right to create ESCs to Accredited Certificate Providers (ACPs) in return for a discount on the cost of the energy savings activity.  The MWh savings from the project determines the number of ESCs that can be created. The ESS works by allowing ACPs to create and register ESCs for energy savings that are supported with appropriate evidence. ESCs are then purchased each year by mainly electricity retailers operating in NSW to meet their share of a legislated annual energy savings target.), and Small-scale Technology Certificates (STC) programs. 

Highlights include the launch of the new Commercial & Industrial (C&I) Solar PVSolar Photovoltaic Activity, ongoing ESCAn energy savings certificate (ESC) is a tradeable certificate created under Division 7 of Part 9 of the Electricity Supply Act 1995. Each ESC represents one notional megawatt hour (MWh) of energy. compliance actions, upcoming changes to emissions factors, co-payment requirements, and deeming periods, updates to ESS and PDRS rules, and the latest battery STCSmall-scale Technology Certificate under the Australian Renewable Energy Target. More market trends in the last Quarter.  



We also provide important updates regarding changes to government fees that may impact future activities and certificate creation. 

As always, our goal is to keep you informed, compliant, and aligned with best practice.

 

For assistance, contact our Compliance Team via compliance@northmoregordon.com



In this Edition:

1. VEU: New C&I Solar PV Activity Guide (Now Live) 

2. Key VEU Updates & ESC Compliance Actions 

3. NSW ESS & PDRS Updates – Rule Changes and Priorities 

4. STC & Battery Market Update – Since 1 July 2025 

5. End-of-Year Shutdown & Holiday Schedule

1. VEU – New Commercial & Industrial Solar PV Activity Guide (Now Live) 

The Essential Services Commission (ESC) has released the Commercial & Industrial (C&I) Solar PV System Activity Guide and the accompanying VEECVictorian Energy Efficiency Certificate Assignment Form under Activity 47, marking a significant expansion of the Victorian Energy Upgrades (VEU) program. 



Key Details 

• Eligibility: Activities can only be undertaken from the date the relevant Accredited Person (APAccredited Provider - a person accredited under the Victorian Essential Services Commission (ESC) to create VEECs for Prescribed Activities.) has been approved to carry out C&I solar activities. 

• System Size: Eligible PV systems range from 30 kW to 200 kW (module capacity), must be grid-connected via a DNSP, and use CEC-approved PV modules and inverters. 

• Accreditation & Timing: Online C&I accreditation applications and VEEC creation open on 25 November 2025. 

• Documentation: The new Activity 47 VEEC Assignment Form must be used for all C&I solar PV claims. 

Partners to Action

• Review and familiarise yourself with the C&I Solar PV Activity Guide and VEEC Assignment Form before quoting or scheduling any installations. 

• Confirm project eligibility – including non-residential site classification, CECThe Clean Energy Council (CEC) is the peak body for the clean energy industry in Australia. It is a not-for-profit, membership-based organisation. It represents and works with Australia's leading renewable energy and energy storage businesses, as well as rooftop solar installers, to further the development of clean energy in Australia. product listings, and DNSP connection approval. 

• Update your internal compliance and documentation processes ahead of the Registry launch on 25 November 2025. 

• Use the Tools and Calculators section on our Northmore Gordon website to assist with estimating VEECs, assessing system eligibility, and validating technical requirements. 

For more information or start the process of sales and/or onboarding please do not hesitate to contact either Madonna on m.ghajar@northmoregordon.com or Sid on  s.bansal@northmoregordon.com 

2. Key VEU Updates (Nov 2025)

• Minimum Co-Payment: Effective 1 Feb 2026 

• Water Heating: $200 (incl. GST) per product (for units up to 700 litres) 

• Space Conditioning: $1,000 (>10 kW) or $200 (<10 kW) 

• Co-payments: Must be paid before VEEC creation and cannot be reimbursed. 

• Electricity Emission Factor (EEF) Change 

EEF reduces from 0.5334 → 0.3930 (1 Feb 2026) – adjust project forecasts and VEEC pricing accordingly. 



2.1 ESC October 2025 Bulletin Highlights 

• Enforcement: 3 x VEU accredited persons sanctioned for falsified information such as photo evidence, falsely claiming for works that didn’t take place. ESC ordered to surrender over $400k VEECs, placed them under suspension from participating under the scheme for 6 months for one and 3 months for the other AP. 

• Inspections: C&I Heat Pump (Activity 44) audits found breaches of co-payment and telemarketing rules. 

• Compliance Reminder: Activity 6 (High Efficiency Air Conditioners) – ESC has conducted a review of the activity and identified soem areas for improvement across installation of Activity 6 products.



(Source: ESC Compliance Bulletin, Oct 2025) 

2.2 VEEC Market Update: Navigating Declining Certificate Prices 

VEEC prices have continued to soften in recent weeks. 



As of 19 November 2025, prices are trading around $75 per certificate, reflecting a notable decline from earlier highs. 



In this evolving market, Northmore Gordon remains focused on supporting our partners to manage risk, optimise returns, and maintain strong project pipelines. 



What Steps Can You Take? 



1. Submit paperwork promptly – Complete and submit all job documentation immediately after installation, and respond quickly to RFIs to avoid delays.



2. Stay updated with market movements – Subscribe to our VEEC Spot Price Newsletter (issued every Monday and Wednesday) for current price insights. Contact us if you’re not on the distribution list. 



3. Review customer incentives regularly – Maintain a margin buffer to protect profitability amid market fluctuations. 



4. Discuss hedging or forward-contracting options – These strategies can lock in VEEC prices and stabilise revenue. 



5. Diversify your activity mix – Explore other eligible VEU activities to broaden your service offering and reduce reliance on one activity type.

3. NSW ESS & PDRS Updates 



ESS Rule Changes (Oct–Nov 2025) 

• New ESS Rule commenced 12 Sept 2025 with transitional updates. 

• Updated Fact Sheets required by 17 Nov 2025. 

• Partner to Action  – Update all your HEERThe Home Energy Efficiency Retrofits (HEER) method may be used to calculate energy savings from a range of household and small business energy efficiency upgrades. In this method, the term ‘energy’ may refer to electricity, gas or both. [NSW] and IHEAB Factsheets accordingly to the updated versions below

Fact Sheet Name & Document hub link 

HEER – upgrades IPART 

HEER – Heat pump hot water heaters HEER – Heat pump water heaters | IPART 

IHEAB – Heat pump hot water heaters IHEAB – Heat pump water heaters | IPART 

• Air-conditioner lifetimes → 12 years. 

• $1,000 co-payment reaffirmed for IHEAB heat pumps. 

• Door-knocking prohibited. 

Northmore Gordon is reviewing and updating all documentation and evidence templates to ensure reporting and consumer-protection fully align with the new ESS Rule. 



3.1 PDRS & PRC Updates – Effective 1 Nov 2025 

• PRC registration fee: ↑ from $0.0309 to $0.0315 per certificate. 

• PDRS Target (2026–27): revised to 0.5 % to reflect market conditions. 

For more information on these changes, please click here

3.2 IPARTIndependent Pricing and Regulatory Tribunal 2025–26 Compliance Priorities 

• Consumer Protection: ACPs accountable for sales conduct & warranty compliance. 

• Deceptive Conduct: Focus on falsified evidence and manipulated baselines. 

• Emerging Activities: Oversight on BESS 2 and D16 methods. 

• Approach: Targeted audits, inspections, and enforcement. 

4. STC Market Trending in the last Quarter 

The battery STC market has been heating up since the Cheaper Home Batteries Program commenced on 1 July 2025. 



Strong uptake from consumers and installers has seen a surge in Small-scale Technology Certificate (STC) creation for battery systems up to 50 kWh. 



The chart below shows how Victoria performed in the STC battery amongst other states in kilowatt hours (kWH) in the last Quarter.

Source: https://cer.gov.au/markets/reports-and-data/quarterly-carbon-market-reports  

The Clean Energy RegulatorThe Clean Energy Regulator is the Australia Government body responsible for accelerating carbon abatement for Australia through the administration of the National Greenhouse and Energy Reporting scheme, Renewable Energy Target and the Emissions Reduction Fund. More (CER) reports higher-than-expected submission volumes and is reviewing applications closely for evidence and product listing compliance. 



All battery systems must use CEC-approved components and be commissioned on or after 1 July 2025 to qualify. 

For further updates and media releases, visit the Clean Energy Regulator website. 

5. End-of-Year Shutdown & Holiday Schedule 

As we close out another busy year, we thank our partners for your ongoing support and collaboration. 

Shutdown Period 

Closing: Tue 23 Dec 2025 @ 5 pm 

Reopening: Mon 5 Jan 2026 @ 9 am 

Submit all pending documentation early to ensure timely processing. 



For assistance, contact compliance@northmoregordon.com or call 03 9046 1914. 

Kind regards,

Northmore Gordon Compliance Team

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What is the Northmore Gordon November Compliance Update about?

The November Compliance Update from Northmore Gordon covers key developments across the Victorian Energy Upgrades (VEU) program, the NSW Energy Savings Scheme (ESS), and Small-scale Technology Certificates (STC) programs, including the launch of the new Commercial & Industrial (C&I) Solar PV Activity, ongoing ESC compliance actions, upcoming changes to emissions factors, co-payment requirements, deeming periods, updates to ESS and PDRS rules, and the latest battery STC market trends.

When does the new Commercial & Industrial (C&I) Solar PV Activity under VEU open for accreditation applications and VEEC creation?

Online C&I accreditation applications and VEEC creation open on 25 November 2025, under the newly released Activity 47 Commercial & Industrial (C&I) Solar PV System Activity Guide from the Essential Services Commission (ESC).

What system sizes are eligible under the new C&I Solar PV Activity?

Eligible PV systems under the C&I Solar PV Activity range from 30 kW to 200 kW (module capacity), must be grid-connected via a Distribution Network Service Provider (DNSP), and must use CEC-approved PV modules and inverters.

What are the new minimum co-payment amounts under VEU, effective from when?

Effective 1 February 2026, the VEU minimum co-payments are $200 (incl. GST) per product for water heating (units up to 700 litres), and for space conditioning, $1,000 for systems over 10 kW or $200 for systems under 10 kW. Co-payments must be paid before VEEC creation and cannot be reimbursed.

How is the Electricity Emission Factor (EEF) changing under VEU?

The Electricity Emission Factor (EEF) will reduce from 0.5334 to 0.3930 effective 1 February 2026, and project forecasts and VEEC pricing should be adjusted accordingly.

What enforcement action did the ESC take against VEU accredited persons in the October 2025 Compliance Bulletin?

According to the ESC Compliance Bulletin (Oct 2025), three VEU accredited persons were sanctioned for falsifying information such as photo evidence and falsely claiming for works that didn't take place. The ESC ordered surrender of over $400k worth of VEECs and placed the accredited persons under suspension from the scheme — 6 months for one and 3 months for the other.

What was the VEEC market price as of 19 November 2025?

As of 19 November 2025, VEEC prices were trading around $75 per certificate, reflecting a notable decline from earlier highs, continuing a softening trend in recent weeks.

What key NSW ESS rule changes took effect in late 2025?

A new ESS Rule commenced on 12 September 2025 with transitional updates, requiring updated Fact Sheets by 17 November 2025. Key changes include air-conditioner lifetimes extended to 12 years, a reaffirmed $1,000 co-payment for IHEAB heat pumps, and a prohibition on door-knocking sales conduct.

What changes were made to the PDRS and PRC scheme effective 1 November 2025?

Effective 1 November 2025, the PRC registration fee increased from $0.0309 to $0.0315 per certificate, and the PDRS Target for 2026–27 was revised down to 0.5% to reflect market conditions.

What are IPART's 2025–26 compliance priorities under the ESS/PDRS?

IPART's 2025–26 compliance priorities include holding Accredited Certificate Providers (ACPs) accountable for sales conduct and warranty compliance, focusing on deceptive conduct such as falsified evidence and manipulated baselines, providing oversight on emerging activities like BESS 2 and D16 methods, and using targeted audits, inspections, and enforcement as the compliance approach.

What has driven growth in the battery STC market recently?

The battery STC market has been heating up since the Cheaper Home Batteries Program commenced on 1 July 2025, with strong uptake from consumers and installers driving a surge in Small-scale Technology Certificate (STC) creation for battery systems up to 50 kWh.

Who should be contacted for VEU compliance assistance or C&I Solar PV onboarding queries?

For general compliance assistance, Northmore Gordon's Compliance Team can be contacted via compliance@northmoregordon.com. For sales or onboarding related to the new C&I Solar PV Activity, contact Madonna at m.ghajar@northmoregordon.com or Sid at s.bansal@northmoregordon.com.

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